[GregNH]

I think what most people try to do when siting MvH is to point out what was known as common knowledge at the time, hence no need for a precedent. A law is man made and man can't can't change nature that is why "it was never doubted that all children born in a country of parents who were its citizens became themselves, upon their birth, citizens also." So when looking beyond that we need to look at law and once your citizenship is determined by a "law" you are not a citizen by nature, or natural born citizen.

[Hugin]

It sounds to me like there was disagreement back then too. They start by stating the most stringent view. Everybody agrees that those people are natural born citizens, but then what about other categories (one citizen parent, born outside the USA, born here with no citizen parent)? But as they said, they didn’t have to answer that because the plaintiff belonged to the former group, so they didn’t.